Upon information and belief, Defendant Saga Communications, is a corporation organized under the laws of Delaware, with its principal place of business at 73 Kerchaval Avenue, Grosse Pointe Farms, Michigan 48236, and a registered agent at The Corporation Trust Company, Corporation Trust Center 1209 Orange St, Wilmington, Delaware 19801. Defendant Saga Communications sells and/or offers to sell products and/or services throughout the United States, including in this Judicial District. Further, Defendant introduces infringing products and/or services into the stream of commerce knowing that they would be sold in this Judicial District and elsewhere in the United States.
JURISDICTION AND VENUE
This is an action for patent infringement arising under the patent laws of the United States, 35 U.S.C. § 271,
This Court has subject matter jurisdiction over this action under 28 U.S.C. §§ 1331 and 1338(a). 7.
This Court has personal jurisdiction over Defendant at least because Defendant has ongoing and systematic contacts with this District and the United States. Specifically, Defendant is a corporation organized under the laws of Delaware, has a registered agent for service of process in Delaware, and has thereby availed itself of the privileges and the protections of the laws of the State of Delaware. 8.
Venue is proper in this District under 28 U.S.C. §§ 1400 (b) and 1391.
COUNT I – INFRINGEMENT OF U.S. PATENT NO. 5,506,866
The allegations set forth in the foregoing paragraphs 1 through 8 are hereby realleged and incorporated herein by reference. 10.
On April 9, 1996, U.S. Patent No. 5,506,866 (the “’866 Patent”), entitled “Side-Channel Communications in Simultaneous Voice and Data Transmission,” was duly and legally